Maybe you shouldn't have to, but why not if you get the results you want?
That is a good question. In my world, I select a strain based on how it performs at normal fermentation temperatures for its species. For ale, that means that the strain should perform well at 20C (68F). If one has to hold the internal temperature of an ale fermentation below 68F in order to achieve one's desired results, then a different yeast strain should be identified. If one is looking for a squeaky clean fermentation, one should use a strain that can achieve that result without having to ferment at lower than normally accepted temperatures. For example, British cultures are not usually squeaky clean because they have been selected for producing flavorful beers at lower gravities than most Americans are used to drinking. As one increases gravity, one increases higher alcohol and ester production because what controls higher alcohol and ester production is combination of genetics and wort composition.
Temperature is often falsely seen as the reason for estery beer. However, that is treating the symptoms, not the problem. I covered this information in detail in "Have You Seen Ester," but I will cover it here in less detail here. What reducing fermentation temperature does is slow metabolism, especially during the exponential growth phase where it increases the replication period. Where yeast genetics play a role in ester production is in the creation of alcohol o-acetyltransferase. There are two alcohol o-acetyltransferase (ATTase) enzymes; namely, AATase 1 and AATase 2, which are encoded via two different genes ATF1 and ATF2. Where wort composition plays a role is carbon to nitrogen (C:N) ratio. The amount of nitrogen that is available after dissolved oxygen is consumed determines the amount of acetyl CoA that is formed during the growth phase (higher gravity wort not only has more carbon, it has more nitrogen). Acetyl CoA is formed by combining acetic acid with coenzyme A; therefore, more acetyl CoA translates to higher acetic acid-based (acetate) esters. Many of the esters that we find objectionable in beer are acetate esters. For example, outside of Hefeweizen and Belgian styles, isoamyl acetate is unwelcome. Isoamyl acetate is the condensation reaction between isoamyl alcohol and acetic acid. Very few of us find ethyl acetate welcome in a beer. Ethyl acetate is the condensation reaction between ethanol and acetic acid.
How does one reduce ester production without holding fermentation temperature artificially low? The first place to start is selecting the appropriate yeast culture for the task at hand. After the appropriate yeast culture has been selected, one should select the lowest protein barley available. To further increase C:N, one can resort to using a percentage of flaked maize or gelatinized corn grits or even go as far as to use a brewing sugar. I am almost certain the higher-gravity versions of IIPA contain a percentage of sugar.
Finally, Anheuser-Busch ferments with a starting gravity of 1.080 at 13C/55F. A fermentation temperature of 13C is not particularly low for a high-gravity lager fermentation, especially one that will be a very lightly flavored beer where any defect sticks out like a sore thumb after dilution with water. The reason that it is possible in large part is the C:N ratio of the grist, which contains a large portion of adjuncts that dilute the overall nitrogen level of the wort.